Contents

Aims and objectives of SEEP

85. The consultation document sets out the vision as:

'2050 vision - Scotland's buildings are near zero carbon
by 2050 and this is achieved in a way that is socially and
economically sustainable'

86.
SEEP aims
to reduce the energy demand, and decarbonise the heating of,
Scotland's built environment in a way that is socially and
economically sustainable. The consultation set out the following
objectives:

by 2032 94% of non-domestic buildings' and 80% of domestic
buildings' heat is supplied using low carbon heat
technologies.

improvements to the fabric of Scotland's non-domestic
buildings results in a 10% reduction, and Scotland's domestic
buildings results in a 6% reduction, in their heat demand by
2032.

SEEP
will also support delivery of the Scottish Government's new Fuel
Poverty Strategy as this is developed.

Question 2: How can Scotland best meet this vision and
underpinning objectives in a way that is both socially and
economically sustainable and supports long-term inclusive
growth?

Summary of main themes:

The need to focus on energy efficiency, particularly given
its importance as a driver in reducing fuel poverty was
highlighted by several respondent, as well as it being a
cost-effective means to decarbonise our heat supply

The need to address fuel poverty and energy affordability was
seen as important priority.

Other priorities included the need to start with existing
buildings or to identify and address the most energy inefficient
buildings; while other respondents commented on the need to
prioritise off-gas areas.

87. 85 respondents commented. Many of these respondents, across
groups, specifically commented that they welcomed the vision, aims
and objectives, with several describing the vision as
'ambitious'.

88. One of the main themes emerging at this question, from
across respondent groups, was the need to focus on energy
efficiency. Respondents gave a number of reasons for this including
the importance of energy efficiency as a driver in reducing fuel
poverty. A small number of respondents quoted from the Scottish
Fuel Poverty Strategic Working Group:
"The statistics illustrate the important influence of energy
efficiency on fuel poverty levels…the incidence of fuel
poverty among the income poor rises to 99% among those in the least
energy efficient properties,
EPC
rating E-G".

89. Other reasons included the benefits to health and wellbeing,
with consequent savings for the
NHS and benefits
to the economy through jobs in the supply chain. Some also
commented that improving energy efficiency is the most
cost-effective route to decarbonise heat. One third sector /
NGO
said:

"Demand side activity can be implemented far more quickly
than changes in the supply side and will allow delivery of carbon
reductions with lower levels of low carbon supply. In addition,
energy efficiency helps improve security of supply by reducing
the demand for primary energy and hence dependence on supply side
investment and energy imports. Most energy saving options are
also more cost effective than investing in any new supply
capacity and energy efficiency can meet multiple government
objectives (including climate change mitigation, fuel poverty
alleviation, improved health and well-being, employment
etc.)".

90. Many respondents, across respondent groups, commented on the
need to start with existing buildings or to identify and address
the most energy inefficient buildings first. Several respondents
also wanted to see priority given to off-gas grid areas

91. Another theme in many responses, again across respondent
groups, was that of tackling fuel poverty, for example one housing
respondent commented that: "
SEEP
should seek to eliminate poor property conditions as a driver for
fuel poverty":

92. Some of these respondents asked for specific and measurable
milestones and targets on fuel poverty to ensure this element is
not lost or overshadowed by other objectives. One energy industry
respondent commented that the
SG will need to be
clear
"on whether the objective will be to reach the Scottish
Government's carbon emissions targets or whether the focus will be
on alleviating fuel poverty. The design and delivery of the scheme
is likely to differ depending on the chosen focus".

93. The aim of tackling fuel poverty was also seen, by a
respondent from the public sector / delivery agency / regulator
group, as a useful way of engaging and raising awareness of
SEEP as it
is something that people will both understand and support.

94. A small number commented on the need for specific action in
relation to fuel poverty in remote and rural areas as this may need
more individual, and therefore more costly, measures.

95. In addition to fuel poverty, several respondents,
particularly from the housing group, mentioned energy
affordability. There were comments on the need for targets for
energy affordability and the need for a focus on affordable warmth.
A respondent from the academia / research / training mentioned that
affordable energy should also encompass businesses as this would
contribute to the economy.

96. Comments on the need to raise consumer awareness and bring
about behaviour change also featured in many responses, again
across most groups. For example:
"The great potential for energy demand reduction by means of
behaviour change must not be overlooked as an element of
SEEP as it
is at present. Well-aimed investment in public awareness/education
is not only necessary but cost-effective" (third sector /
NGO).

97. Raising awareness amongst the business industry was
mentioned in a response from the public sector / delivery agency /
regulator group with the comment:
"Building industry awareness of the key milestones of
SEEP will
be vital to achieving its vision and objectives".

98. The need for local delivery and local supply chains was also
a key theme, appearing in many responses across respondent groups.
Several of these respondents, particularly from the building /
insulation group, commented on the potential benefits to local jobs
and economies and a suggestion that using local companies could
help to raise awareness among the wider community. There was also a
comment that local assessors and advisers would be useful as they
would understand the local area and buildings.

99. The need for flexibility to meet the needs of local areas
was stressed and a small number commented on the introduction of
Local Heat and Energy Efficiency Strategies (
LHEES)
which, an energy industry respondent commented,
"could provide an effective framework for Scotland to deliver
on its objectives in a way that is socially and economically
sustainable". They also commented that
"it will be for Scottish Government centrally to ensure the
combination of these strategies meets national targets, as well as
ensuring they are aligned with
UK targets". There
were, however, comments on the need to ensure local authorities are
well supported and resourced to enable them to develop and
implement
LHEES.
There were also comments on the need to ensure that issues for
remote and rural locations are addressed.

100. Several respondents, particularly from the energy industry,
commented on the need for clear, measurable objectives and targets
with clear, long term, timescales and associated resources. There
were calls for long term national policy support and the need for
both national and local authority leadership, for example:
"By setting clear long-term goals with appropriate milestone
targets, the Government can help to reinstate confidence in policy,
drive investment in innovative, low carbon technologies and
encourage the deployment of energy efficiency solutions"
(energy industry).

101. A small number mentioned the need to learn from schemes in
other countries. Examples given included the Energiesprong approach
which is delivering net zero carbon retrofits in the Netherlands;
experience in Denmark where
"those in the market for a new home are provided with greater
transparency of running costs (including utility costs) at point of
sale/rental" (energy industry). The municipalisation of energy
supply in Europe was also highlighted as an example of delivering
economic and social benefits to local communities.

102. Other themes to emerge, in small numbers of responses,
included:

The need for clear definitions, particularly with regards the
phrase 'near zero carbon'.

The need to learn lessons from previous schemes, particularly
issues with the Green Deal.

The need for cross working across the
UK and challenges
around devolved and non-devolved issues.

The need for partnership working, between sectors but also
between relevant public sector bodies including the
NHS.

The need for independent advice and assessors to ensure
quality.

The need to ensure private sector engagement.

The need to attract private sector investment.

The need to consider other energy sources such as
LPG, hydrogen or
recycled
CO
2.

The need to future-proof the programme to ensure new
technologies can be considered.

Question 3: We would welcome stakeholders' views on how
to set appropriate milestones for energy efficiency improvement
and heat decarbonisation of buildings to ensure that the level of
emissions reduction ambition (i.e. near-zero carbon buildings) is
achieved.

Summary of main themes:

The need for final targets to be long-term was highlighted by
a number of respondents, explaining that this will enable
planning and allow for market and behaviour change.

There were requests for targets to be realistic and
achievable and to take into account, or be aligned with, targets
and policies in other areas. Some respondents commented on the
need for targets and milestones for sub-sectors of the building
stock or occupant groups, including for fuel poor households or
off-gas areas.

The need for 'real' rather than modelled data to assist in
target setting, particularly in relation to Energy Performance
Certificates (
EPCs).

103. 76 respondents commented on this question.

104. A main theme from responses was that final targets need to
be long-term to enable planning and allow for market and behaviour
change. Some of these respondents were concerned that any short
term targets could be subject to change and that this would harm
rather than help to achieve the final goals.

105. A small number of respondents noted that there would need
to be a long enough lead-in time to communicate and raise awareness
of targets, as well as to provide advice and support. A third
sector /
NGO
respondent commented:

"We advise long term milestones are set to provide time for
landlords, be they social or private, to plan and set aside
resources as well as to inform tenants of the benefits of this
work to help overcome any obstacles and for owner occupiers to
plan for any financial implications".

106. Several respondents, across groups, stressed that milestone
targets should be realistic and achievable. There was a suggestion
that milestones be set with industry to ensure realistic
timescales. For example:

"We also believe that the key to the successful implementation
of
SEEP will
be in setting achievable milestones. [The respondent] would
recommend that when setting the trajectory for milestones, the
level of ambition should gradually be increased over time. This
will enable planned growth in the supply chain and hence help to
ensure that both sustained, quality employment for local
tradespeople and quality installations for consumers are
successfully delivered as a result of
SEEP."
(building / insulation)

107. In addition, one energy industry respondent suggested that
the trajectory for milestones should increase over time and
suggested that this could be phased to coincide with times when
major renovations are most likely to be undertaken.

108. A small number commented that milestones need to be set for
each of the
SEEP
objectives.

109. While there was a little difference in opinion as to
whether interim milestones should be set, most of the small number
who commented on interim milestones felt that these would be
useful.

110. The need for specific milestones and standards for domestic
and non-domestic were seen as necessary by a small number,
particularly from the energy industry group, in order to meet the
different targets for reductions in carbon emissions. There was a
comment, from the energy industry, that these milestones should
reflect the timescales for planned reduction in carbon
emissions.

111. A small number of respondents outlined the order in which
targets should be set and met with some commenting on the need to
begin with ways to reduce demand. However, the need for demand
reduction measures and heat decarbonisation measures to work
together was also stressed. A small number commented that the
targets [on demand reduction ] (10% reduction for non-domestic and
6% for domestic sectors) could be more ambitious.

112. Specific targets and milestones for eliminating fuel
poverty (as well as carbon emissions) were also seen as a priority,
by a number of local government and third sector /
NGO
respondents, as was the need to prioritise district heating. A
small number, across various groups, called for a milestone of
EPC band
C by 2025, commenting that
EPCs are
useful target as they are widely known and readily understood.

113. Another priority identified by several respondents was a
focus on off-gas grid areas. A small number suggested a milestone
of all homes in these areas being highly insulated and heated by
renewable, low carbon and affordable heat sources by 2025.

114. Several respondents, from various groups, commented on the
need for any milestones to take into account, or be aligned with,
targets and policies in other areas. A building / insulation
respondent gave the example that the Draft Climate Change Plan
favours the use of timber, however high thermal mass materials
could help deliver energy efficiency targets. Furthermore, a small
number of respondents commented on the need for policies to be
rural-proofed so that they do not discriminate against rural
areas.

115. There was a query, from a respondent from the academia /
research / training group, as to whether the final goal is
eliminating fuel poverty or zero carbon, as these will necessitate
different benchmarks. A small number also said that there should be
equal priority given to both environmental and socio-economic
considerations.

116. The need for more, and more current, data on energy
consumption was mentioned by several respondents who suggested that
this should be real world rather than modelled data. In addition,
respondents wanted to see real world validation of the outcomes
from any measures introduced.

117. There were further suggestions, each from one or two
respondents, for targets or how they could be set including:

Milestones for electrical goods and appliances, pegged to
monitored progress of the
DEFRA
Market Transformation Programme.